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ISCC scope

What your ISCC certificate actually covers

A valid ISCC certificate is not the same as a certificate that covers the cargo you are selling. The difference sits in the annex, it is the single most common reason a sustainability declaration gets rejected, and it usually surfaces at the buyer's audit rather than yours.

A certificate number proves you are certified. The annex proves what you are certified FOR, and only the second one matters for a specific cargo. Material may only be handled as sustainable if it is included in the certificate annex of the system user. Two valid certificates can still fail to line up: if your annex covers a material your buyer's annex does not, they cannot receive it as sustainable, and the sustainability declaration is worthless to them. That is not a paperwork detail, it is the difference between a certified cargo and an ordinary one, and the price gap between those two is the whole point of being certified.

What a document actually has to prove
  1. 1Origin of the material
  2. 2Chain of custody
  3. 3Mass balance bookkeeping
  4. 4Scheme certificate
  5. 5Claim on the invoice

A claim is only as good as the weakest box to its left.

The annex is the document, not the certificate

Almost every scope problem starts the same way: someone checks that the counterparty holds a valid certificate, sees a number and an expiry date, and stops there. The certificate says the company passed an audit. The annex says which materials and which activities that audit covered.

Material can only be handled as sustainable if it appears in the annex of the system user's certificate. Parts of a supply chain that are not certified cannot handle material as sustainable and may not issue sustainability declarations at all.

  • Check the annex, not the front page. Ask for it explicitly; it is a separate list and it is not always sent along.
  • Check the activity too. Producing, trading with storage, trading without storage and warehousing are different scopes.
  • Check the date against your laycan. A certificate that expires between loading and discharge is a problem you want to find now.

"Entirely or partly of animal origin", what that line means

This wording turns up on certificates for used cooking oil and related materials, and it causes more confusion in practice than almost any other phrase on the document.

It is a description of what the certified material may contain. UCO collected from kitchens and restaurants will in practice contain animal-derived fat, so the scope has to say so. The consequence is downstream: your buyer needs a scope that allows them to receive that same description. A buyer whose annex covers only vegetable-origin material cannot take it as sustainable, even though the cargo is genuinely certified and genuinely sustainable.

Neither party is doing anything wrong in that situation. The two scopes simply do not overlap, and the cargo has to find a buyer whose scope does.

The animal by-product rules run alongside this and are a separate question again, see used cooking oil for the material and proof of sustainability for what has to be on the declaration itself.

Two certified companies can still fail to trade

This is the part that surprises people who are new to certified trade. Both sides hold valid certificates, both are audited, both act in good faith, and the sustainability claim still cannot pass between them.

Where it usually goes wrong:

  • The material is not on the buyer's annex. They can buy the cargo; they cannot book it as sustainable.
  • The product group is different. Similar-looking products are not interchangeable: FAME from used cooking oil and FAME from rapeseed are not physically identical and do not belong to the same product group. Physical, chemical and RED-category criteria all have to be met together before materials may be grouped.
  • The chain of custody method does not line up. Mass balance, segregation and controlled blending have to be coherent from end to end, not chosen separately by each party.
  • A link in the chain is not certified at all. Any entity taking legal ownership has to be certified, or the chain of custody breaks at that point.

The expensive version of this is when it surfaces at the buyer's audit rather than at the seller's. By then the cargo has moved, the invoice is out, and the claim is being unwound after the fact.

Trading without storage is still a scope

A persistent misunderstanding among traders who never physically touch the material: that not handling it means not needing certification.

Since 1 August 2023, materials for traders, both paper traders and traders with storage, as well as warehouses and logistic centres have to be included in the annex of the certificate. Taking legal ownership is what triggers the requirement, not taking physical possession.

For a trading company this has a practical consequence worth planning around: your annex has to be broad enough to cover everything you might take title to, and extending it is an audit matter with a lead time, not a phone call.

Why the GHG number can fail even when the scope fits

A separate question that arrives in the same conversation often enough to belong here: a cargo can be in scope, correctly certified, and still not meet the greenhouse gas saving the buyer needs.

The saving is calculated over the whole chain, collection, processing, transport, and any losses along the way, against a fossil comparator. Long shipping legs and energy-intensive processing eat into it. Which threshold applies depends on the installation and the route, and the buyer's own obligation may require more than the legal minimum.

So "why can you not reach 65%" is usually not a dispute about honesty. It is arithmetic over a specific chain, and the honest answer is to show the calculation rather than argue about the number.

What to ask before you commit

Five questions, answerable in one email, and they prevent the failure that otherwise surfaces months later at somebody's audit.

  • Send me your annex, not your certificate. The number tells me you are certified; the annex tells me whether we can trade.
  • Which exact material description do you hold? Word for word, as it appears on the annex.
  • What is your chain of custody method? And does it match what my side uses.
  • Does your scope cover the activity you will perform on this cargo? Storing, blending and reselling are not the same entry.
  • What GHG value are you working to, and who calculated it?

Frequently asked questions

Does my ISCC certificate cover this product?

Only if the material appears in the annex of your certificate. The certificate itself shows that you were audited; the annex shows for which materials and which activities. Material that is not in the annex may not be handled as sustainable, and an uncertified part of a supply chain may not issue sustainability declarations at all.

What does "entirely or partly of animal origin" mean on a certificate?

It describes what the certified material may contain. Used cooking oil collected from kitchens will in practice contain animal-derived fat, so the scope says so. The consequence sits downstream: your buyer needs a scope that allows them to receive that same description. A buyer whose annex covers only vegetable-origin material cannot take it as sustainable, even though your cargo is properly certified.

Can two certified companies still be unable to trade certified material?

Yes, and it happens regularly. Both certificates can be valid while the scopes do not overlap: the material is not on the buyer's annex, the product groups differ, the chain of custody methods do not line up, or a link in the chain is not certified. Nobody is at fault; the trade simply cannot carry the sustainability claim.

Are FAME from used cooking oil and FAME from rapeseed the same product group?

No. They are not physically identical and they do not belong to the same product group. Physical characteristics, chemical characteristics and the RED category all have to be met together before materials may be grouped, so similar-sounding products cannot be substituted for one another under a single entry.

I am a trader and never handle the material. Do I still need certification?

Yes, if you take legal ownership. Since 1 August 2023 materials for traders, paper traders as well as traders with storage, and for warehouses and logistic centres have to be included in the certificate annex. Legal ownership is what triggers it, not physical possession, and a chain of custody breaks at any uncertified link.

What happens if the scope does not match?

The cargo can still be sold, but not as sustainable material. The sustainability declaration cannot be issued or cannot be accepted, so the buyer books ordinary material and the premium disappears. The worst case is that it surfaces at the buyer's audit after delivery, when the claim has to be unwound after the fact.

Why can a supplier not reach a 65% GHG saving?

Because the saving is calculated over the whole chain against a fossil comparator, and collection, processing, transport and losses all count against it. A long shipping leg or energy-intensive processing can put a genuinely sustainable cargo below a threshold. Ask for the calculation rather than the number; a supplier who can show it is usually telling the truth.

What should I ask a counterparty before committing?

Their annex rather than their certificate, the exact material description as it appears on it, their chain of custody method, whether their scope covers the activity they will perform on this cargo, and what GHG value they work to and who calculated it. Five questions, one email, and they prevent the failure that otherwise appears months later at an audit.

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Sources and further reading

Primary sources for the rules and figures on this page, so you can check them yourself. Legislation is amended: always read the consolidated text on the date that matters to you.

Who to ask about ISCC certificate scope

Just ask. Not sure whether your scope covers what you are about to sell, or whether your counterparty can receive it? Send both certificates and the material description. You get Bart van den Brug on the other end, same working day, in English or Dutch, and across the team also in French, Portuguese, Polish, Czech and Russian.

On how we work: on the feedstocks and fuels on this site we are a broker. We never take title, we do not trade our own book, and we are paid a commission on business that concludes. Additives are the one exception: those we also buy and sell for our own account, and we say in which capacity we are acting before you commit to anything. Either way you will hear it from us when the answer is no, or when your parcel is not ready for the conversation you want to have. A market read or a second opinion on a specification costs nothing and commits you to nothing.

Happy to look at whatever you have, even if it is half an analysis and a question.

+31 6 115 83 448
bart@sustainablecommodities.eu
Sustainable Commodities 3 B.V., Lemmer, the Netherlands

Ask about ISCC certificate scope

Specification, volume, location and certification are enough to start.

Or e-mail us directly: bart@sustainablecommodities.eu

Last reviewed 03 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.